CARB Consumer & Commercial Products SurveyAnd Related Air Quality Issues

March 19, 2015SATA 2015 Spring MeetingMarriott Perimeter CenterAtlanta, Georgia

D. Douglas FratzSenior Science Fellow & Aerosol Products Division Staff Executive

Washington, DC - USA

Today’s Presentation

• CARB 2013/2014/2015 Consumer & Commercial Product Surveys

• 2016 California Ozone SIP & South Coast AQMP

• ACP-Based Voluntary Measure

• CARB and Industry LVP/VOC Fate Research

• VOC Compliance Initiatives

• EPA SNAP Proposal HFC Phase Down

• EPA Ozone Standard Revision

CARB’s Stated Purposes for the 2013/2014/2015 Surveys

• Emissions Inventory Update– VOC Emissions and LVP-VOC Emissions

• 2016 State Implementation Plan Measures

• Support LVP Research and Policies

• Future Consumer Product Regulations

CSPA Estimates of the Scope of CARB’s Proposed Survey

CARB 2006 Survey CARB Proposed 2013 Survey

100 Product Categories 490+ Product Categories

20,000-30,000 Products 300,000-500,000 Products

About 500 Companies 3000 Companies

25-50 Data Points/Product 200-300 Data Points/Product

More Than Two Years Required 90 Days to Complete Forms

Some CBI Sensitivity Massive CBI Collection

About $5 Million Industry Costs At Least $50 million/year

One Year’s Data Three Year’s Data

CSPA Negotiation Results – Key Wins

• Numerous Products Categories Removed

• Grouping for Non-Volatile Ingredients

• No Reporting of Fragrance Components

• Included CSPA List of Semi-Volatile LVPs – Others Grouped

• Product Formulation Grouping

• CBI Claims Facilitated

• Less Reporting for Aerosol Coatings

• Commitment to Consider Extension Requests

• Fixed Numerous Problems in Software Tools

Product Sectors Not Previously Surveyed

• Scented Candles

• Arts & Craft Supplies

• Aerosol Foods

• Fuels (Other Than Lighter Fluids)

• Non-FIFRA Lawn & Garden and Pet Care Products

• Office Supplies

• Pool/Spa/Jacuzzi/Pond Products

• Health Use Products (External OTC Drugs)

• Numerous Products in “Other” Sector Categories

CARB Survey Extensions

• CSPA Meeting with CARB on February 12

• CARB Extension Policy Announced February 19

• 30 Days for Formulators (April 1)

• 120 Days for Small Businesses (July 1)

• Responsible Parties Extensions on Request

• All Requests Were Granted – But 30 Days Only

• Potential Issue: Enforcement for Late/No Submission?

• CSPA Will Work to Protect Members From Fines

2013 Survey Data Quality Review

• Discussed at CSPA/CARB Meeting 2/12/15

• CARB Wants to Complete Review by December

• Intends to Update Inventory for 2016 SIP!

• CSPA Will Propose QC Process Involving Industry

• Review Companies Reporting by Sector

• Remove Industrial Products/ Others Outside Scope

• Correct Product Categorizations

• Correct Ingredient Categorizations

• Correct Product Form Categorizations

• Other Corrections Impacting Inventory

CARB Schedule for 2014/2015 Surveys

• 2014 Sales Data and New Formulations

• Survey Begins July 2015

• Submission Deadline November 2015

• 2015 Sales Data and New Formulations

• Survey Begins July 2016

• Submission Deadline November 2016

CSPA Plans to Negotiate 2014/2015 Survey Changes

• Discussed at CSPA/CARB Meeting 2/12/15

• Goals: Reduce Paperwork Burden and CBI Risks

• Possible Changes:

• Remove Non/Minimal-VOC Product Categories

• Flexible Definition for New Products

• Flexible Definition for New Formulations

• Grouping of Sales Data by Category

• No Reporting for Minimal Sales Changes?

• More Grouping of Ingredients

2016 CARB SIP/ SCAQMD AQMP• 75 ppb Ozone Standard (Current SIP 84 ppb)

• Attainment in South Coast in 2031

• Due to EPA in July 2016

• South Coast and CARB Attainment Modeling Already Started

• Further Reductions: Up to 90% NOx and 50% VOCs?

• SCAQMD Public Process Begins Later This Year– VOC White Paper Workgroup

– AQMP Workgroup

• CARB SIP Process to Follow AQMP Process

• Not Clear How Survey Data/ LVP Research Will be Used

CSPA Conceptual Proposal for ACP-Based Voluntary Reduction Measure

• CARB Alternative Compliance Plan

• Excess VOC Reductions Occur Each Year

• Few Companies Using (Paperwork Burdens)

• CSPA Conceptual Proposal

– Voluntary and Emerging Measure

– Capture Excess Reductions as SIP Credit

– Include Bundled Measure in 2016 SIP

• CSPA Working to Secure EPA Approval

Defense of the LVP Exemption

• South Coast Objecting to CARB LVP Exemption

• CSPA and Broad Industry Coalition (ARR) was Formed to Defend

• CARB Funding $600,000 in LVP Studies

• Chamber Studies at UC-Riverside

• Fate Modeling at UC-Davis

• ARR Funding Complimentary LVP/VOC Research

• Fate Modeling by SENES (ACC-Funded)

• Emissions Inventory Assessment by UC-Riverside (ARR-Funded)

Update on CARB-Funded Research• UC Riverside Chamber Studies

– LVP Evaporation Studies/ Product Formulations

– Chamber Photochemistry: Ozone and PM

– CSPA Members Providing Formulations/Materials

– CSPA Seeking More “Real-Life” Chamber Conditions

– Contract Ends September 2016

• UC Davis Environmental Fate Modeling

– Fate for LVPs Emitted in Air or Water

– Modeling Completed/ Draft Report

– Completion Targeted for September 2015

• CARB Conference Call Update Scheduled for March 24

• CSPA and ARR Science Team will Comment on Studies

• CARB Research Screening Committee Approval

Completed ARR-Funded LVP/VOC Research

• SENES LVP/VOC Environmental Fate Modeling

– 43 VOCs, 9 Exempted VOCs, 23 LVPs

– Environmental Fate: Air/Water/Soil/Sediments

– Most Consumer Product LVPs and VOCs Partition Out of Air to Water, Soil or Sediment (Less Ozone Formation)

– Results Often Very Different from CARB UCD Modeling

– CSPA and ARR Science Team Seeking to Explain Differences

Completed ARR-Funded LVP/VOC Research

• UC Riverside VOC Emissions Inventory Study

– Current CARB VOC Emissions Inventory for Consumer Products and Architectural Coatings – 280 TPD

– 35% of coatings, 10% of personal care, and 17% of CSPA Products VOC emissions in Inventory are LVP-VOCs

– Inventory Chemicals’ Thermodynamic Properties Predictive of Alternative (Non-Air) Fate Potential for Most VOCs/LVPs• Down-the-Drain, Combusted, Solid Waste, Polymer Film, Collected

as Waste Solvent, Partitions to Water or Surfaces

Further ARR-Funded LVP/VOC Research

• Possible Further Studies Could Include:

– Assessment by SENES of UCD Modeling Study Results

– Chamber Studies or Modeling of Indoor Fates

– Further Studies on Outdoor LVP/VOC (Non-Air) Fates

– Air Quality Modeling of Ozone Impacts for LVPs/VOCs

• ARR Science Team Plans to Make Recommendations on Further Research After March 24th Update on CARB Research

VOC Compliance Initiatives

• Retailer VOC Compliance

• CSPA Work with The WERCS

• Plans for CSPA Retailer Compliance Conference

• CSPA Request for Guidance/Advisories

– Discussed at CSPA/CARB 2/12/15 Meeting

– Labeling Multiple Dilutions for Multiple Limits

• CARB Product Category Determination Form

EPA SNAP Proposal HFC Phase Down• EPA Significant New Alternatives Policy Program

• Proposed Rule to De-List HFC-134a Uses (8/6/14)

• CSPA Meetings with EPA SNAP Officials

• CSPA Comments Filed October 20,2014

– Support Retaining Critical Uses of 134a

– Urged Extending Deadline to 1/1/18 & 1/1/17 (From 1/1/16)

– Asked that Variance Procedure Be Adopted

• Final Rule Expected in July or August 2015

• EPA Developing USA GHG Inventory Projections

• EPA/DOS Seeking Montreal Protocol Revisions for HFCs

EPA Ozone Standard Revision

• Health-Based Standard

• Supreme Court: Economics Not Considered

• Proposed to Lower to 65-70 ppb (12/17/14)

• NGOs Advocating 60 ppb

• Nonattainment in 45 states?

• Approaching Background Levels

• NAM Annual Cost Estimate: $140 Billion– $1.7 Trillion 2017-2040 loss in GDP

– 1.4 Million Jobs Lost

• Final Rule in September 2015

CSPA Actions to Date• CSPA Comments to EPA Against Lowering Standard in 2010

• Coordinating Efforts with Major NAM-led Coalition– Grass-Roots Campaign to Engage State Officials

– Conducted Extensive Economic Impact Assessment

– Support for Newly Introduced Federal Legislation

• Participated in SBA Roundtable (1/23/15)

• Testified at EPA Hearing (1/29/15)

• CSPA Comments to EPA on New Proposal (3/17/15)– Urged EPA to Retain 75 ppb Standard

– Allow States to Implement Current Standard First

– Experience in Implementation Will Help Determine What Measures are Effective (and Cost-Effective) in Further Lowering Ozone

Summary and Conclusions

• 2015 will be a critical year

• Many issues need to be resolved

• They will not resolve themselves.

• GET INVOLVED!

Thank You! Questions?

D. DOUGLAS FRATZSenior Science Fellow &Aerosol Products Division Staff Executive

Consumer Specialty Products Associationdfratz@cspa.org

Washington, DC - USA